SC ruling on whether order section 263 is barred by limitation

CIT Vs. Mohammed Meeran Shahul Hameed (Supreme Court)

The short question of law which is posed for consideration before this court is,

1. whether in the facts and circumstances of the case, the High Court and the learned ITAT are right in holding that the order passed by the learned Commissioner passed under Section 263 was barred by period of limitation provided under Section 263 (2) of the Act?

2. Whether the High Court is right in holding that the relevant date for the purpose of considering the period of limitation under Section 263(2) of the IT Act would be the date on which the order passed under Section 263 by the learned Commissioner is received by the assessee?

Held that :

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